Baby It’s Cold Outside…So Remember OSHA’s Cold Stress Guide

As much of the country is experiencing record low temperatures, it is a good reminder that failing to take appropriate measures to protect employees working in such environments and avoiding other hazards associated with the cold such as preventing slips on snow and ice could provide the basis for a general duty violation under OSHA. OSHA’s tagline for employers to prevent cold stress-related injuries and illnesses is “Plan, Equip, Train.”

The Guide provides answers to some common questions including: (1) how cold is too cold? (2) what are the risk factors that contribute to cold stress? (3) how does the body react to cold conditions? (4) what are the most common cold-induced illnesses/injuries? (5) what is hypothermia? and (6) what is frostbite?

Employers should also understand risk factors for cold stress may include:

Wetness/dampness, dressing improperly and exhaustion

Predisposing health conditions such as hypertension, hypothyroidism, and diabetes

Poor physical conditioning

OSHA recommends employers take several affirmative steps to prevent cold-related injuries and illnesses including (1) training employees to recognize cold stress and how to apply first aid treatment; (2) implementing engineering controls such as radiant heaters; (3) using safe work practices such as providing plenty of warm sweetened liquids to workers; and (4) ensuring employees are dressed properly.

OSHA identifies several hazards including slips and falls while working on snow and ice, falls from roofs and roof edges, through skylights, or from aerial ladders and lifts. Other hazards associated with recovery work include being struck by vehicles, carbon monoxide, hypothermia and being injured by powered equipment. As always, proper employee training to recognize these hazards is the key to preventing them.

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The Editor

John S. Ho
John S. Ho exclusively represents employers in labor and employment matters including but not limited to safety and health matters under OSHA and similar state law plans. John also defends employers in the numerous retaliation statutes enforced by OSHA. Prior to joining Cozen O'Connor, John was a prosecutor for the United States Department of Labor, Office of the Solicitor where he enforced OSHA among other federal statutes. John serves as the chair of Cozen O’Connor’s OSHA practice area. His complete bio can be reviewed here.

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